New proposals from East Sussex County Council again threaten to remove cycle access to the town centre. As a group we have serious concerns and we have listed our answers to the current public consultation below so others can use them as a basis for their own replies. The online consultation form is quite restrictive, so we recommend you email your objections directly to Eastbournephase2b@eastsussex.gov.uk. The consultation closes on 20 November 2022 so please do reply before then.
Update: We have provided some example ways to object to the Eastbourne town centre cycle ban.
Question 8 – Do you have any general comments on the proposed Eastbourne Town Centre Movement and Access Package Phase 2b proposals?
The proposals as outlined in the consolation brochure are significantly lacking in many areas and work to permanently exclude cycling from Eastbourne town centre. As a result, many areas of the proposals are not compliant with local and national policy and design standards for active travel, including (but not limited to):
- The Gear Change Plan
- The Cycling and Walking Investment Strategy 2
- Local Transport Note (LTN) 1/20
- Local Cycling and Walking Infrastructure Plans Technical Guidance for Local Authorities
- The Government’s 2021 Transport Decarbonisation Plan
- East Sussex Local Cycling & Walking Infrastructure Plan 2020-2030
The key areas of concern outlined by Bespoke Cycle Group will be discussed in more detail under their respective question headings. A summary of these concerns however is outlined below.
Bespoke object to the proposals to remove cycling access on the sections of Terminus Road between Langney Road and Road, and between Seaside Road and Grand Parade (Victoria Place). There is no concrete evidence to suggest that there have been any collisions between pedestrians and cyclists in the current pedestrian and cycle zone. The removal of cycling access is also not compliant with Local Transport Note (LTN 1/20) Section 7.4 and does not support wider active travel policy goals (e.g., Gear Change, Cycling and Walking Investment Strategy 2) to increase cycling mode share in Eastbourne.
The memorial roundabout proposals could be significantly improved by implementing 20mph speed limits on streets leading up to/away from the roundabout and installing a ‘Dutch-style’ layout with cycle lanes and associated cycle crossing points.
For the ring-road proposals, far more will need to be done if the overall goals of reducing traffic along Ashford/Susan’s Road and improving conditions for pedestrians and cyclists are to be realised. This includes the installation of segregated cycle lanes, a 20mph zone with associated traffic calming, and pavement widening.
Bespoke’s position is that the project team need to do far more to improve cycling access to the town centre, which is currently lacking, and risks being removed all together if the proposals go through in their current form. The lack of policy compliance, particularly with regards to LTN 1/20, also removes the possibility of the areas of the proposals outside of Victoria Place receiving funding from the Active Travel Fund. Bespoke remind the project team that phase 2a of the town centre failed to achieve funding from the Department for Transport Active Travel Fund for exactly this reason. East Sussex County Council (ESCC) also failed to receive any funding from the latest round of the Active Travel Fund (Tranche 3) and their overall track record in delivering active travel improvements has been poor.
Question 14 – Do you have comments about the proposed improvements to Terminus Road?
In their current form, Bespoke object to the proposed improvements to Terminus Road for the overarching reason that, in line with the substandard phase 2a proposals (which Bespoke also objected to), they will permanently remove cycling access to Eastbourne town centre. Current policy on active travel is clear that local authorities should be making concrete steps to increasing cycling mode share for short to medium length journeys (see Gear Change). For most people living in Eastbourne, the town centre is within a 3-mile distance; a distance that would be easily cyclable by many able-bodied residents if safe cycling routes were provided.
The pedestrianised sections of Terminus Road, including the section between Langney Road and Seaside Road offer a safe, direct, and traffic free route for cyclists choosing to cycle to the town centre shops or between the station and the seafront. Currently, the pedestrianised sections of Terminus Road covered by the proposals are clearly marked as pedestrian and cycle zones, meaning that cyclists are permitted to cycle through these areas at all times, and park their bikes close to shops and services. Converting the pedestrian and cycle zones into pedestrian only zones will require a Traffic Regulation Order (TRO) under the Road Traffic Regulation Act 1984. The project team should not press ahead with proposals for a TRO restricting cycling along this section of the Terminus Road for the following reasons.
- The removal of cycling access along Terminus Road is not compliant with LTN 1/20. Paragraph 7.4.2 states that “Vehicle Restricted Areas (VRAs, otherwise known as pedestrianised streets) are often important destinations for access to shops and services by cyclists, and for through-cycle traffic. A high street is usually the most direct route across a town centre. Requiring cyclists to travel longer distances via routes around the zone, possibly on heavily trafficked roads, will tend to suppress cycle trips and reduce cycle safety”. This is particularly the case for Eastbourne town centre, as surrounding roads such as Ashford Road, Grove Road, and Seaside Road are heavily congested and are dangerous for cyclists, particularly children, elderly, disabled cyclists, and less confident cyclists.
- Following on from this, paragraph 7.4.3 of LTN 1/20 states that “there should always be a preference for allowing cyclists to access VRAs unless there is good evidence that this would cause significant safety problems”. Data from Crash Map indicates that there have been no collisions between pedestrians and cyclists on the stretches of Terminus Road and Victoria Place covered in the proposals. Following on from this, paragraph 7.4.3 also states that “Where cycling is permitted, most cyclists will usually dismount when pedestrian numbers are greatest”. Most cyclists in Eastbourne town centre use common sense when cycling along Terminus Road and will naturally slow down or dismount when encountering large pedestrian volumes.
- On page 22 of the consultation brochure, the project team have misinterpreted the updated Highway Code (2022) which refers to user behaviour whilst travelling and should not be used as the main justification for design choices, particularly when other guidance such as LTN 1/20 has clearly been ignored. The current proposals remove cycling access whilst continuing to provide priority for cars and other vehicles on surrounding streets. As such, the project team have clearly placed cyclists below private vehicles in the hierarchy of users outlined within the updated Highway Code.
- Page 8 of the consultation brochure states that all the proposals aside from the Victoria Place
pedestrianisation are currently unfunded. When applying for Active Travel Funding, the Department for Transport will now only be able to support schemes which comply in every respect with LTN 1/20 guidance. Removing cycling access along Terminus Road will remove the possibility of some the proposals receiving funding through the Active Travel Fund. It will also reflect badly on future Active Travel Fund bids from ESCC, who received no funding as part of Tranche 3 due to their active travel schemes not being LTN 1/20 compliant, and also received no funding for phase 2a of the Eastbourne town centre improvement for the same reason. Future scores received by ESCC on the Active Travel England Self-Assessment may also be negatively affected.
- The proposed pedestrian only zone will mean that cyclists will be unable to access the pedestrianised areas at all times and could potentially be fined for cycling along Terminus Road no matter what speed they are cycling at. This will also require enforcement officers to stop cyclists, which adds additional unnecessary costs to the council and the taxpayer at a time when council budgets for Eastbourne are stretched.
- The proposals will negatively impact delivery cyclists picking up orders from local restaurants and takeaways, with several of these restaurants being located within the proposed scheme area. This would be unpopular with the owners of these businesses and may negatively affect trade. It may also encourage these businesses to switch to motorised delivery vehicles.
- The proposed re-development of the former TJ Hughs building has recently received planning permission. This will include 65 new apartments and a cycle store with 100 spaces. Residents may wish to cycle to Eastbourne station along Terminus Road, and either park their bikes at the station or take their bikes on the train for an onward journey. Should the proposed pedestrian only zone be implemented, the most direct route to the station and seafront for residents who wish to cycle will be severed, with alternative routes being indirect and unsafe. On top of this, other future town centre developments (such as the redevelopment of the former magistrate’s court on Old Orchard Road) quoted projected increases of over 100% for both bus and cycle usage as part of their planning applications, which was signed off by both Eastbourne Borough Council (EBC) and ESCC. It is not clear how these increases will be realised with restricted cycling access in the town centre.
- The removal of cycle access discriminates again cyclists with disabilities, and those using larger
non-standard bikes that carry children or heavier items of shopping. Research by Wheels for Wellbeing (Disability and Cycling) outlines that more than 64% of disabled cyclists say that cycling is easier than walking for them. Requiring these groups to dismount upon reaching Terminus Road may be challenging, or for some, impossible.
- National policy on active travel (Gear Change Plan, Cycling and Walking Investment Strategy 2) sets out ambitious targets to increase the percentage of short journeys in towns and cities that are walked or cycled to 46% by 2025, and 50% by 2030. Both EBC and ESCC have also declared climate emergencies, with the former also having an ambitious net zero target of 2030. Restrictions on cycling in the town centre will put people off cycling to the town centre at a time when there needs to be a wider modal shift to this transport mode for short to medium length journeys within Eastbourne.
- There are currently no other town centres in East Sussex with pedestrianised areas that restrict cycling access, so there is no local precedent for removing cycling access as part of the proposals. Other towns and cities in the UK, including Oxford, Norwich, and Croydon (London) have proven that cyclists can safely access pedestrianised areas without causing danger to pedestrians.
- A 2016 study from the World Health Organisation (WHO) found that Eastbourne was the third worst settlement in the UK for PM2.5 air pollution, and the seventh worst for larger PM10 pollution. Traffic congestion in the town forms a large part of this. Reducing car usage across the town and encouraging modal shift will be vital in reduce air pollution in the town and encouraging cycling must form a large part of this strategy. Restricting cycling access to the town centre is the wrong way to do this and will encourage people to use other more polluting forms of transport including cars, vans, and diesel buses.
- East Sussex remains 17th out of 18 Local Authorities in South East for cycling numbers and mode share according to Department for Transport data. This is largely down to the lack of safe cycle routes throughout the county. Removing safe cycling access in Eastbourne town centre as part of the proposals will do nothing to improve East Sussex County Council’s ranking in this regard.
- Finally, the removal of cycling access to Eastbourne town centre sets a bad precedent that cyclists as a road user group are a danger to pedestrians, despite no local or national evidence suggesting this is the case. It will undermine further improvements to cycling infrastructure in Eastbourne, which currently lacks safe, connected, and segregated cycle paths between key destinations within the town and has banned cycling on the seafront promenade.
Based on the above, Bespoke’s recommendations with regards to cycling on Terminus Road are as follows:
- The existing pedestrian and cycle zone on Terminus Road between Langney Road and Seaside Road should be retained in its current form to ensure full LTN 1/20 compliance. The design of the paving, which has clearly demarked surfacing to direct delivery vehicles, could also work to mark out an area to cycle along with appropriate floor markings.
- The proposed pedestrianised area on Victoria Place should be marked as a pedestrian and cycle zone, or a dedicated cycle lane provided along the centre of the pedestrianised area. This will also complete a safe cycle route running from the station to the seafront, allowing cyclists to avoid heavily congested surrounding arterial roads.
- The proposals for cycle parking should be maintained as is, but further cycle parking should be included along all sections of Terminus Road outlined in the proposals. These should be Sheffield stands of a sturdy design and located in areas with good visibility and lighting.
Question 17: Do you have any comments on the proposed improvements to Memorial Roundabout?
Bespoke believe more could be done to improve safety for cyclists on the roundabout. The implementation of a 20mph speed limit on roads leading up to and away from the roundabout should be included as a minimum, but installing cycle lanes around the roundabout, in a ‘Dutch style’ layout should also be considered. The recent approval of a similar style of roundabout in Hailsham on Diplocks Way/South Road/Ersham Road, which features segregated cycle lanes with cycle crossing points, proves that this can be achieved with limited space. This would also provide future opportunities to install fully segregated cycle lanes along Devonshire Place to the seafront, or along Cornfield Terrace/Chiswick Place towards Devonshire Park.
Question 19: Do you have any further comments on the proposed relocation of the Ring Road?
Bespoke believe that far more needs to be done with this proposal if the objectives of reducing traffic along Ashford/Susan’s Road and improving conditions for pedestrians and cyclists are to be realised. Replacing signage and road markings doesn’t go far enough, especially given that local driver knowledge, sat-navs, and applications such as Waze will mean that many drivers will simply continue to use Ashford Road and Susan’s Road. This will mean that the Ashford Road and Susan’s Road will continue to suffer from congestion, poor air quality, and dangerous conditions for pedestrians and cyclists. Bespoke suggests the following improvements to be implemented as part of the wider ring-road proposals.
A 20mph speed limit should be implemented along Ashford Road and Susan’s Road, supported
by traffic calming measures where necessary.
The left-hand lane of traffic on the Ashford Road one-way system should be significantly reduced in width or removed entirely to allow space for a two-way segregated LTN 1/20 compliant cycle lane and widened pavements between the station and the junction with Ashford Road/Cavendish Place. This would represent a huge upgrade on the sub-standard shared-use path currently proposed for this location and would also allow for more space for pedestrians. It would also tie into the proposed town centre to Horsey Way cycle route.
Question 23: Do you have any further comments about the public consultation?
Bespoke have a number of concerns about the consultation brochure, the consultation questionnaire, and the way in which the consultation for the proposals has been undertaken:
- The questionnaire in its current form includes several clearly weighted questions, and completely ignores the needs of cyclists. In particular, Bespoke have concerns about the weighting of three identical questions (questions 5, 6b, and 11) asking about the scheme improving pedestrian safety. These answers are clearly obvious given that they refer to a pedestrianised area of the town and responses to these questions may be used as justification for removing cycling access.
- Even though the brochure includes options to provide comments in writing, Bespoke do not consider that equal weight will be given to the qualitative (free written) answers over the quantitative (tick box) answers. Rather, it is felt that the tick box questions will be used as ‘headlines’ to push the proposals through even if concerns around cycling access are outlined in the written questions.
- It is noted in the consultation brochure (page 7) that non-motorised user groups have been included in focus groups on the proposals. Bespoke have not received any correspondence on the project proposals prior to the start of the public consultation, despite being the main cycling campaign group in Eastbourne, and therefore representing a key non-motorised user group.
- The wording of the brochure does not highlight cycling in a positive light. Cycling is not mentioned under the active travel benefit and the brochure focuses more on the reasons why cycling needs to be restricted rather than encouraged. This position clearly represents ESCC’s view on cycling as a mode of transport.
- As mentioned in a previous point, the use of the updated Highway Code (2022) and the hierarchy of users is not an acceptable justification for removing cycling access, particularly when official design guidance such as LTN 1/20 has not been mentioned within the consultation brochure and no cycling infrastructure has been provided as part of the proposals.